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#2280128 - 01/23/23 04:03 PM Affordable Multifamily
Tennismom Offline
Platinum Poster
Tennismom
Joined: Jan 2004
Posts: 778
We have a loan for affordable multifamily property that is $300,000. Know this is HMDA reportable, but can we report both as a HMDA loan and a CD loan even if the loan amount is less than or equal to $1,000,000?

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CRA
#2280181 - 01/24/23 04:31 AM Re: Affordable Multifamily Tennismom
Len S Offline
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Joined: Oct 2004
Posts: 2,090
Connecticut
This is one situation you can report as both a HMDA loan and a CD loan if it qualifies as a CD loan. I assume you took a mortgage on the property so it's secured by residential property.
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#2280182 - 01/24/23 12:48 PM Re: Affordable Multifamily Tennismom
Tennismom Offline
Platinum Poster
Tennismom
Joined: Jan 2004
Posts: 778
Correct, For clarity, no matter the loan amount be it <=$1,000,000 or >$1,000,000 we can report as a CD loan?

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#2280212 - 01/24/23 07:36 PM Re: Affordable Multifamily Tennismom
Len S Offline
Diamond Poster
Joined: Oct 2004
Posts: 2,090
Connecticut
The loan size is irrelevant for multifamily housing. It is relevant when its a loan to a small business because it must be reported as a small business loan and double counting is not allowed except for multifamily mortgages.
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#2280214 - 01/24/23 07:48 PM Re: Affordable Multifamily Tennismom
Rocky P Online
Power Poster
Joined: Jun 2003
Posts: 7,659
Florida
I don't know if this has been updated, but the FRB Dallas has a loan grid for CRA.
https://www.newyorkfed.org/medialib...lasFed-CRA-Loan-Data-Collection-Grid.pdf
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#2281561 - 02/24/23 08:08 PM Re: Affordable Multifamily Tennismom
NU Rhules Offline
Gold Star
NU Rhules
Joined: Mar 2011
Posts: 476
SE, Nebraska
I am really missing something here. You mean except for multi-fam housing reporting HMDA and reporting CRA is not allowed? I didn't know HMDA was tied to CRA. We are getting ready to becoming an ISB bank, and no training I've attended has mentioned this. I get squeemish thinking I might not report a HMDA reportable loan on the LAR. Can someone tell me where this guidance is located? Not even the FDIC's training mentioned this.

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#2281586 - 02/25/23 08:56 PM Re: Affordable Multifamily Rocky P
didimark Offline
Junior Member
Joined: Apr 2020
Posts: 47
I believe Dallas Fed has a newer version:

https://www.dallasfed.org/~/media/documents/cd/pubs/craloan.pdf
Last edited by MJZMJZ; 02/25/23 08:58 PM.
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#2281594 - 02/27/23 02:51 PM Re: Affordable Multifamily Tennismom
Rocky P Online
Power Poster
Joined: Jun 2003
Posts: 7,659
Florida
What is reportable for each of the regulations is in the regs.
HMDA is the HMDA Getting it Right/Guide to HMDA reporting https://www.ffiec.gov/hmda/guide.htm

CRA - A Guide to CRA Data Collection https://www.ffiec.gov/cra/guide.htm
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